Tax Attorney in Erie, PA
Federal IRS representation for Erie individuals and businesses — audits, back taxes, liens, levies, payroll-tax disputes, FBAR work for Great Lakes US-Canada cross-border accounts, and U.S. Tax Court litigation at the Pittsburgh trial city, with a Buffalo alternate. We also coordinate Pennsylvania Department of Revenue matters under PA Form REV-677 Power of Attorney where they sit alongside a federal case.
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If you owe back taxes in Erie, here is the 2026 picture
Pennsylvania carries a flat 3.07% personal income tax under 72 Pa.C.S. § 304 — one of the lowest flat rates in the country — and Erie carries a local Earned Income Tax of 1.65% on resident wages under Pennsylvania Act 32 (administered through the Erie County Tax Collection Committee). Erie County does not impose a local sales tax, so the combined sales rate inside the City of Erie is the state 6% under 72 Pa.C.S. § 7202 with no county add-on. Pennsylvania also imposes an inheritance tax at 4.5% on transfers to lineal descendants, 12% on transfers to siblings, and 15% on transfers to non-relatives under 72 Pa.C.S. § 9116 — one of only six states that still levies a separate inheritance tax. Stack the state and local pieces on the 37% federal top rate and a Wabtec Lawrence Park RSU vest, an Erie Insurance Group equity-comp year, a UPMC Hamot 1099 physician season, or a Bosnian-American refugee family with inherited overseas accounts can produce a five- or six-figure tax exposure in a single year.
If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the Pennsylvania Department of Revenue has issued a Notice of Assessment with proposed tax, penalty, and interest, the deadline to act is short. We pull your IRS account transcripts, calculate your CSED, file Form 2848 with the IRS and Form REV-677 with the PA DOR, and put administrative brakes on collection while the case is built.
Federal tax representation for Erie taxpayers
Victory Tax Lawyers, LLP is a California-Bar-admitted tax-resolution law firm based in Los Angeles. Our federal practice runs nationwide: the Internal Revenue Service accepts our Form 2848 Power of Attorney in every state, and the U.S. Tax Court — a single federal tribunal with jurisdiction over IRS deficiency cases — holds regular trial sessions in Pittsburgh at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street, roughly 130 miles south of Erie, with Buffalo, New York approximately 130 miles east as an alternate trial city for petitioners in Northwestern Pennsylvania and the Western New York border counties. From our Robertson Boulevard office in Los Angeles, we represent Erie residents and Pennsylvania-domiciled businesses in IRS audits, collection cases, Tax Court petitions, Offers in Compromise under IRC § 7122, Installment Agreements under IRC § 6159, lien discharges under IRC § 6325, levy releases under IRC § 6343, and Trust Fund Recovery Penalty defenses under IRC § 6672.
For Pennsylvania state tax matters — the flat 3.07% personal income tax under 72 Pa.C.S. § 304, the 8.99% corporate net income tax (phasing down to 4.99% by 2031) under 72 Pa.C.S. § 7401, the 4.5% / 12% / 15% Pennsylvania Inheritance Tax under 72 Pa.C.S. § 9116, the 6% state sales-and-use tax (Erie County imposes no local add-on, so 6% is the combined rate inside Erie) under 72 Pa.C.S. § 7202, withholding-tax assessments, or contested matters headed to the Pennsylvania Board of Finance and Revenue — we file PA Form REV-677 with the Department of Revenue and handle the administrative track directly. For formal litigation before the Pennsylvania Commonwealth Court (which sits in Harrisburg at 601 Commonwealth Avenue, Suite 2100, and hears tax appeals from the Board of Finance and Revenue) or the Pennsylvania Supreme Court, we refer to locally admitted Pennsylvania counsel under a co-counsel arrangement. The federal layer is where most Erie Wabtec locomotive-manufacturing, Erie Insurance Group equity-comp, UPMC Hamot and Saint Vincent physician, and Port of Erie maritime cases live, and that is where our engagement carries the load.
Erie sits at the center of a Northwestern Pennsylvania economy built on four distinct waves: the Great Lakes shipping legacy of the Port of Erie on Lake Erie, with Canadian cross-border trade, St. Lawrence Seaway maritime work, and a tightly regulated US-Canada customs environment under IRC § 7202 sales-tax responsible-person rules and the parallel FinCEN Form 114 (FBAR) regime for Canadian RBC, TD, BMO, and Scotiabank accounts held by dockworkers, ship captains, and shipping-line employees; the locomotive-manufacturing legacy of GE Transportation in Lawrence Park, sold to Wabtec in 2019 and still running as the Wabtec Lawrence Park plant on East Main Street producing diesel-electric and battery-electric locomotives, with substantial W-2 plus RSU vesting and § 174 R&D capitalization on the engineering side; the insurance and financial-services cluster anchored by Erie Insurance Group (Erie Insurance Exchange) headquartered downtown at 100 Erie Insurance Place — a Fortune 500 carrier with RSU, ISO, actuarial 1099, and Schedule C insurance-agency exposure across the region; and the academic and medical engine of Mercyhurst University, Gannon University, Penn State Behrend, Edinboro University, UPMC Hamot, Saint Vincent Hospital, and AHN Saint Vincent. Add Presque Isle State Park and Lake Erie tourism (with IRC § 280A short-term rental exposure on the bayfront and lakefront), Presque Isle Downs racing, the Erie SeaWolves Double-A baseball affiliate playing at UPMC Park, Mercyhurst NCAA hockey, Niagara Falls cross-border commuter and treaty-residency work, and Erie's African-American, Hispanic, Iraqi-American, Burmese-American, Vietnamese, and Bosnian-American refugee communities (Erie's Bosnian-American population resettled through Catholic Charities and the International Institute starting in the mid-1990s and remains one of the larger per-capita Bosnian communities in the country), and the tax-resolution footprint is high-W-2-equity-compensation, 1099 physician underwithholding, FinCEN Form 114 work on overseas family and refugee-origin accounts, § 174 R&D capitalization for Wabtec engineering and the Erie tech ecosystem, § 280A short-term rental analysis for Presque Isle and Lake Erie peninsula properties, and lake-effect winter casualty-loss claims under IRC § 165(h). The federal procedures are uniform; the facts are Erie-specific.
Your tax rights as an Erie taxpayer
Two parallel rights frameworks apply when you owe tax. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights come from the Pennsylvania Consolidated Statutes Title 72, the Department of Revenue's Taxpayer Rights Advocate office, and the procedural rules of the Pennsylvania Board of Finance and Revenue. Knowing both is the difference between a clean resolution and a missed 60-day Board of Finance and Revenue petition window that locks in a state assessment against your Frontier, Glenwood, or Millcreek Township property.
Right to representation
IRC § 7521(b)(2) and (c) give you the right to be represented by an attorney, CPA, or Enrolled Agent during any IRS examination or interview. Once Form 2848 is on file, the IRS must deal with us first, not you. Pennsylvania mirrors this through PA Form REV-677 Power of Attorney, accepted for all Department of Revenue matters.
Right to U.S. Tax Court review
IRC § 6213(a) gives you 90 days from a Statutory Notice of Deficiency to petition the U.S. Tax Court without paying the tax first. Miss the 90 days and the federal assessment becomes final. The U.S. Tax Court holds regular trial sessions in Pittsburgh at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street — the primary trial city for Erie County petitioners. Buffalo, New York at the Robert H. Jackson United States Courthouse, 2 Niagara Square, is the alternate roughly 130 miles east for petitioners closer to the New York border.
Right to PA Board of Finance and Revenue review
72 Pa.C.S. § 9702 and the Board's procedural rules give you 60 days from a final PA Department of Revenue Board of Appeals decision to file a petition with the Pennsylvania Board of Finance and Revenue at 1101 South Front Street, Suite 400, Harrisburg. The 60-day window is shorter than the federal 90-day Tax Court deadline. Missing it forfeits the right to administrative review of the state assessment before judicial appeal to the Pennsylvania Commonwealth Court.
Collection Due Process
IRC § 6320 (lien) and IRC § 6330 (levy) give you a 30-day window to request a CDP hearing once the IRS files a Notice of Federal Tax Lien or issues a Final Notice of Intent to Levy. A timely CDP filing halts collection and preserves judicial review through the U.S. Tax Court.
Right to settle for less than owed
Federally, IRC § 7122 authorizes Offers in Compromise based on doubt as to liability, doubt as to collectibility, or effective tax administration. Pennsylvania runs a Deferred Payment Plan program and a more selective Compromise program under 72 Pa.C.S. § 9707 administered by the PA DOR, with hardship and insolvency standards similar to but tighter than the federal framework. Both programs require all returns filed and current-year compliance before consideration.
Right to recover fees
IRC § 7430 allows recovery of administrative and litigation costs if the IRS takes a position that is not substantially justified and the taxpayer prevails. The threshold is high, but real, especially in audit reconsideration and Innocent Spouse cases under IRC § 6015.
How Victory Tax Lawyers helps Erie taxpayers
Offer in Compromise under IRC § 7122
We file Form 656 with Form 433-A(OIC) or 433-B(OIC), document the Reasonable Collection Potential, and negotiate doubt-as-to-collectibility offers when full collection is not feasible within the remaining CSED. For Erie taxpayers carrying a parallel Pennsylvania liability, we coordinate a PA Compromise petition under 72 Pa.C.S. § 9707 with the DOR on the same financial showing, sequencing the two programs so an accepted federal Offer does not break a pending state offer or vice versa.
Installment Agreements under IRC § 6159
Streamlined IAs (under $50,000), partial-pay IAs under IRC § 6159(d), and full-pay agreements. We push for partial-pay structures where the IRC § 6502 ten-year CSED will extinguish the balance before payoff — the most under-used resolution path for Erie taxpayers carrying between $50,000 and $250,000 in federal debt, particularly UPMC Hamot and Saint Vincent 1099 physicians who never made quarterly payments, Wabtec Lawrence Park engineers and managers with concentrated RSU vests, Erie Insurance Group equity-comp recipients, and small-business owners across Millcreek and Harborcreek.
Lien discharge, subordination, and withdrawal
When a Notice of Federal Tax Lien blocks an Erie property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Erie County Recorder of Deeds at the Erie County Courthouse, 140 West 6th Street, encumber title on Frontier, Glenwood, Millcreek Township, Harborcreek, Fairview, Lawrence Park, North East, and the bayfront and Presque Isle peninsula properties; the IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing date.
Levy release under IRC § 6343
Wage levies, bank levies, and accounts-receivable levies. We document economic hardship under IRC § 6343(a)(1)(D) and Treasury Reg. § 301.6343-1(b)(4), and where the levy is procedurally defective, we challenge it through Collection Due Process or Appeals. Pennsylvania state tax liens follow a parallel track under 72 Pa.C.S. § 7805 and are recorded in the Prothonotary's office for the county where the taxpayer holds real property; in Erie that is the Erie County Prothonotary at the Erie County Courthouse, 140 West 6th Street.
Audit defense and U.S. Tax Court litigation
Correspondence audits, office audits, and field examinations — including sensitive issues like cryptocurrency, foreign accounts under FinCEN Form 114 (FBAR) for Canadian and Bosnian-origin family accounts, S-corporation reasonable-compensation, § 83(b) election validity, § 174 R&D capitalization timing for Wabtec engineering contractors and Erie-based tech firms, § 280A short-term rental analysis for Presque Isle and Lake Erie peninsula vacation properties, and § 199A Specified Service Trade or Business limits on insurance-agency and actuarial Schedule C income. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Erie petitioners can elect the Pittsburgh trial city at 700 Grant Street or the Buffalo, New York trial city at the Robert H. Jackson United States Courthouse, 2 Niagara Square, depending on convenience.
Penalty abatement under IRC § 6651 and IRM 20.1.1
First-Time Abate administrative relief, reasonable-cause abatement, and statutory exceptions for failure-to-file and failure-to-pay penalties. On accuracy-related penalties under IRC § 6662, we document substantial authority or adequate disclosure to defeat the assessment. Lake-effect winter weather disasters routinely qualify Erie taxpayers for casualty-loss relief under IRC § 165(h) when federally declared, and reasonable-cause abatement when the storm explains a late filing. Pennsylvania penalties under 72 Pa.C.S. § 352 (failure to file) and § 353 (failure to pay) follow a separate reasonable-cause analysis applied by the PA DOR and reviewable by the Board of Appeals and then the Board of Finance and Revenue.
Twelve types of Erie tax matters we handle
Federal cases for Erie residents and businesses, framed against the PA DOR and Erie Local Earned Income Tax overlay where it matters.
Port of Erie maritime FBAR and customs
The Port of Erie is a Great Lakes shipping point on Lake Erie with active US-Canada cross-border trade, St. Lawrence Seaway maritime traffic, and a tightly regulated customs environment. Dockworkers, ship captains, mates, line handlers, and shipping-company employees who hold Canadian RBC, TD, BMO, or Scotiabank accounts — or Canadian RRSP or TFSA balances from prior employment — carry FinCEN Form 114 (FBAR) reporting obligations once aggregate foreign-account balances cross $10,000 at any point during the year. IRC § 7202 also imposes responsible-person liability on shipping-line officers and check-signers for unpaid sales and use tax and federal employment-tax withholding. We handle Streamlined Filing Compliance Procedures, delinquent FBAR submissions, and customs and trust-fund cases together.
Wabtec Lawrence Park RSU and § 174 R&D
The Wabtec Lawrence Park plant on East Main Street — formerly GE Transportation, sold to Wabtec in 2019 — produces diesel-electric and battery-electric locomotives and remains the dominant heavy-manufacturing employer in Erie County. Wabtec engineers, managers, and equity-holders frequently carry RSU vesting with the standard 22% supplemental withholding shortfall against a 32% to 37% federal marginal rate, plus 3.07% Pennsylvania PIT and 1.65% Erie Local Earned Income Tax. The post-2022 IRC § 174 amendment requires capitalization and five-year amortization of domestic research and experimental expenditures (15-year for foreign R&D), which catches engineering contractors and small Erie tech firms working on locomotive electronics, battery systems, and rail-control software.
Erie Insurance Group RSU, ISO, and § 199A SSTB
Erie Insurance Exchange — the Fortune 500 insurance carrier headquartered downtown at 100 Erie Insurance Place — sits at the center of the regional financial-services economy. Erie Insurance Group employees carry RSU and ISO equity-comp exposure tied to ERIE common stock, while independent Erie Insurance agents file Schedule C insurance-agency returns. The IRC § 199A Qualified Business Income deduction phases out for Specified Service Trades or Businesses (which includes insurance agency and brokerage activities) once taxable income crosses the inflation-indexed threshold — the SSTB analysis is a recurring engagement for Erie agency owners. Actuarial 1099 consultants and Erie-based actuarial-services firms add their own § 199A and self-employment-tax layer.
UPMC Hamot and Saint Vincent 1099 physician underwithholding
UPMC Hamot, Saint Vincent Hospital, and AHN Saint Vincent anchor the Erie medical economy. Attending physicians, surgical specialists, anesthesiologists, and pathologists frequently carry side 1099 income from independent surgical centers, telemedicine, clinical-trial honoraria, and pharmaceutical-royalty arrangements. The federal Schedule C self-employment exposure plus 15.3% SECA under IRC § 1401, the Pennsylvania 3.07% PIT, and the Erie 1.65% Local Earned Income Tax on resident wages can land a UPMC Hamot or Saint Vincent physician with a five- or six-figure balance due the spring after a strong year.
Pennsylvania Inheritance Tax exposure
72 Pa.C.S. § 9116 imposes the Pennsylvania Inheritance Tax at 4.5% on transfers to lineal descendants (children, grandchildren), 12% on transfers to siblings, and 15% on transfers to nieces, nephews, and non-relatives. Pennsylvania is one of only six states still imposing a separate inheritance tax. Frontier, Glenwood, Millcreek Township, Harborcreek, Fairview, and Lawrence Park estate values regularly cross the threshold where the 4.5% tax adds up to a meaningful number, particularly when sibling transfers (12%) or non-relative bequests (15%) come into play. Form REV-1500 is due within nine months of death and filed with the Erie County Register of Wills at the Erie County Courthouse, 140 West 6th Street; a 5% discount is available for prepayment within three months.
Trust Fund Recovery Penalty
IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Erie targets are restaurant owners along State Street and the bayfront, hospitality operators around Presque Isle State Park and Presque Isle Downs, construction and dockworker contractors at the Port of Erie, healthcare staffing companies serving UPMC Hamot and Saint Vincent, and small manufacturers in the Lawrence Park and Wesleyville industrial corridors. The IRS uses Form 4180 interviews to identify responsible persons. Pennsylvania applies a parallel responsible-person rule to withheld state income tax and sales tax under 72 Pa.C.S. § 7240.
Presque Isle short-term rental § 280A
Bayfront and Lake Erie peninsula short-term-rental properties around Presque Isle State Park, the Bayfront Highway corridor, and North East wine country face IRC § 280A vacation-home and material-participation tests, plus Schedule E versus Schedule C classification questions for properties run with hotel-like services. Pennsylvania levies its 6% Hotel Occupancy Tax under 72 Pa.C.S. § 7202 on STR receipts where the rental is 30 days or less, with a 2% Erie County Hotel Room Excise Tax added at the county level (separate from the sales tax, which is 6% with no Erie County add-on). Cost segregation, bonus depreciation under IRC § 168(k), and material-participation analysis under Treasury Reg. § 1.469-5T are recurring planning issues for owners along the peninsula and the lake.
Notice of Federal Tax Lien
NFTLs filed with the Erie County Recorder of Deeds at the Erie County Courthouse, 140 West 6th Street, encumber title and trigger CDP rights under IRC § 6320. A parallel Pennsylvania state tax lien may be recorded under 72 Pa.C.S. § 7805 in the Erie County Prothonotary's office. Frontier, Glenwood, Millcreek Township, Harborcreek, Fairview, Lawrence Park, North East, and bayfront-and-peninsula closings stall fast when an NFTL hits the title search.
IRS bank or wage levy
Bank levies on accounts held at PNC Bank, Erie Bank (a Marquette Savings division), Erie Federal Credit Union, First National Bank of Pennsylvania (FNB), Northwest Bank (Warren, PA-headquartered and active across Erie County), Citizens Bank, or any Pennsylvania-chartered institution. Wage levies hit Erie employers within days of CP90 or LT11 issuance — including Wabtec Lawrence Park, Erie Insurance Group, UPMC Hamot, Saint Vincent Hospital, AHN Saint Vincent, Mercyhurst University, Gannon University, Penn State Behrend, Edinboro University, and the larger small-and-mid-size manufacturers across Lawrence Park and Wesleyville.
Niagara Falls and US-Canada cross-border
Niagara Falls, New York sits roughly 135 miles east of Erie, and the Peace Bridge crossing at Buffalo and the Lewiston-Queenston Bridge at Niagara push a steady volume of US-Canada commuter traffic through Northwestern Pennsylvania. Cross-border commuters carry treaty-residency analysis under Articles 14, 15, and 17 of the US-Canada Income Tax Convention, FinCEN Form 114 FBAR exposure on Canadian RBC, TD, BMO, and Scotiabank accounts, Canadian RRSP and TFSA reporting on Form 8938 under IRC § 6038D, foreign-tax-credit calculations under IRC § 901, and the IRC § 217 moving-expense deduction (limited post-2017 to active-duty military) when employment-driven relocation crosses the border.
Bosnian, Burmese, and refugee FBAR
Erie's Bosnian-American population, resettled through Catholic Charities and the International Institute of Erie starting in the mid-1990s, remains one of the larger per-capita Bosnian communities in the United States. Iraqi, Burmese, Vietnamese, and more recent refugee arrivals carry their own family-account histories abroad. Inherited or family-business accounts at Raiffeisen, UniCredit, Sparkasse, or other European or Southeast Asian institutions trigger FinCEN Form 114 reporting once aggregate foreign-account balances cross $10,000. The IRS Streamlined Filing Compliance Procedures (Domestic and Foreign Offshore) are a frequent engagement, paired with ITIN applications under IRC § 6109 for non-resident family members reported on US returns.
Mercyhurst, Gannon, Behrend, Edinboro academic and clergy
Mercyhurst University (Catholic, founded 1926), Gannon University (Catholic, founded 1925), Penn State Behrend (the Erie campus of the Pennsylvania State University), and Edinboro University (now part of Pennsylvania Western University) drive the academic side of the Erie economy. Adjunct and clinical-faculty 1099 income, post-doctoral fellowship reporting under IRC § 117(c), clergy housing allowances under IRC § 107 for Catholic priests and religious community members affiliated with Mercyhurst and Gannon, and visiting-scholar treaty-residency analysis for international faculty are recurring engagements. Mercyhurst NCAA Division I men's and women's hockey programs also push some athlete and coach Schedule C income onto the tax map.
Nine common causes of tax debt for Erie taxpayers
Patterns we see repeatedly in Erie-based engagements. None of them are unusual — all of them are resolvable.
1. Underwithheld RSU and ISO vest events
A Wabtec Lawrence Park engineer or manager, an Erie Insurance Group equity-comp recipient, or an employee at one of Erie's mid-cap manufacturers at the 32% or 35% federal marginal bracket sees only 22% supplemental withholding on RSU vests. The shortfall, plus 3.07% Pennsylvania and the 1.65% Erie resident Local Earned Income Tax, produces a five- or six-figure balance due the following April.
2. Self-employment underpayment
UPMC Hamot and Saint Vincent attending physicians with private 1099 practices, AHN Saint Vincent specialists, Mercyhurst, Gannon, Penn State Behrend, and Edinboro adjunct faculty, Erie Insurance agency owners filing Schedule C, dockworker independent contractors at the Port of Erie, and Lake Erie tour-boat and charter-fishing operators file Schedule C or K-1 income with no estimated-tax payments. The first IRS CP14 lands the following spring with penalties under IRC § 6654.
3. Business closure
When an LLC, S-corp, or family-owned Erie restaurant, hotel, or shipping-services firm closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Common in the seasonal Lake Erie tourism cycle and in restaurant turnover along State Street and the bayfront.
4. Divorce and joint-return fallout
A jointly-filed return tied to a now-former spouse's understatement leaves both parties liable until Innocent Spouse relief under IRC § 6015 is granted.
5. Identity theft and fraudulent returns
A return filed in your name with refund redirected. Form 14039 opens the IRS identity-theft case; the assessment must be corrected, not just protested. Pennsylvania has its own DOR identity-theft and Fraud Investigation Unit that runs in parallel.
6. Cryptocurrency CP2000 surprise
Exchanges issue Form 1099-DA (introduced 2025), and the IRS computer matches reported gains. Missed basis records turn into ordinary-income assessments at the full sale price.
7. Late-filed or unfiled returns
Failure-to-file under IRC § 6651(a)(1) compounds at 5% per month, capped at 25%. After three years, refunds are barred under IRC § 6511. Pennsylvania mirrors the federal three-year refund bar under 72 Pa.C.S. § 346. Lake-effect winter storms have repeatedly pushed Erie filers past deadlines — reasonable-cause abatement is on the table when documentation supports it.
8. Real-estate sale without estimated tax
A Frontier, Glenwood, Millcreek Township, Harborcreek, Fairview, or peninsula bayfront sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. Pennsylvania taxes the gain at the flat 3.07% rate with no separate capital-gain category. Erie resident sellers also owe the 1.65% Local Earned Income Tax on the gain only if it is characterized as earned income (typically dealer-status under IRC § 1221), not investment income.
9. Stock-option exercise without planning
ISO disqualifying dispositions and NSO ordinary-income inclusions hit Erie Insurance Group, Wabtec Lawrence Park, and Erie mid-cap manufacturing employees with AMT under IRC § 55 and large balances due. IRC § 83(b) elections missed within the 30-day window create their own irreversible problem — especially costly for early-stage equity-holders in Erie tech and engineering spin-outs whose early-grant basis was low.
Eight tax liabilities that pull in Erie taxpayers
Federal authority alongside the Pennsylvania statute where there is a parallel.
Failure to file federal return
IRC § 6651(a)(1) imposes 5% per month, capped at 25%, plus interest under IRC § 6601. The Pennsylvania mirror is 72 Pa.C.S. § 352 imposing a 5% per month late-filing penalty (minimum $5, capped at 25%) on unpaid Pennsylvania tax.
Failure to file Pennsylvania return
72 Pa.C.S. § 352 imposes a 5% per month penalty on the unpaid tax for failure to file, capped at 25%, plus interest under 72 Pa.C.S. § 806. The PA DOR may issue a Notice of Assessment triggering an internal Board of Appeals window, with further review by the Pennsylvania Board of Finance and Revenue under 72 Pa.C.S. § 9702 within 60 days of the Board of Appeals decision.
Federal § 7122 Offer in Compromise eligibility
All federal returns must be filed (IRC § 7122(d) compliance) and the offer must reflect Reasonable Collection Potential. The non-refundable $205 application fee may be waived for low-income certified offers.
Pennsylvania sales-tax delinquency
72 Pa.C.S. § 7202 sets the 6% state sales tax on retail sales of tangible personal property and certain enumerated services. Erie County does not add a local sales tax, so the combined Erie sales rate is 6% (compared with 7% in Allegheny County and 8% in Philadelphia). 72 Pa.C.S. § 7240 imposes personal liability on responsible persons for unpaid trust-fund sales tax. The Pennsylvania use tax under 72 Pa.C.S. § 7202 is enforced against businesses purchasing equipment out of state, including marine and shipping equipment shipped to the Port of Erie.
Trust Fund Recovery Penalty
IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. Pennsylvania applies a parallel responsible-person rule to withheld state income tax and sales tax under 72 Pa.C.S. § 7240. Erie enforcement targets restaurant, hospitality, healthcare-staffing, dockworker, and small-manufacturing owners across Erie County.
Accuracy-related penalty
IRC § 6662 imposes 20% on substantial-understatement or negligence; IRC § 6663 imposes 75% on fraud. Defense is built on substantial authority, adequate disclosure, or reasonable cause. 72 Pa.C.S. § 353 imposes a parallel underpayment penalty at the state level.
Pennsylvania Inheritance Tax
72 Pa.C.S. § 9116 imposes Pennsylvania Inheritance Tax at 4.5% on transfers to lineal descendants, 12% on transfers to siblings, and 15% on transfers to non-relatives. Pennsylvania is one of only six states that still imposes a separate inheritance tax. Form REV-1500 is filed with the Erie County Register of Wills at the Erie County Courthouse, 140 West 6th Street, within nine months of death; a 5% discount is available for prepayment within three months of death.
FBAR and FATCA non-disclosure
FinCEN Form 114 (FBAR) is required for any US person with a financial interest in or signature authority over a foreign financial account exceeding $10,000 in aggregate at any time during the year. Erie's Bosnian, Iraqi, Burmese, Vietnamese, and Canadian cross-border populations carry the bulk of the FBAR exposure in Northwestern Pennsylvania. IRC § 6038D and Form 8938 add a parallel FATCA filing obligation at higher asset thresholds. Streamlined Filing Compliance Procedures and Delinquent FBAR Submissions are the two main remediation paths.
What resolution can look like
Debt reduced
An accepted IRC § 7122 Offer in Compromise can resolve six-figure balances for cents on the dollar where Reasonable Collection Potential supports the offer. The acceptance rate sits around 33% nationally; preparation determines the outcome.
Penalties abated
First-Time Abate removes a single year of failure-to-file or failure-to-pay penalties for taxpayers with a clean three-year compliance record. Reasonable-cause abatement under IRM 20.1.1 reaches further when supported by documentation — including federally declared lake-effect winter disasters in Erie County.
Lien released or withdrawn
Once a debt is paid in full, the IRS releases the Notice of Federal Tax Lien within 30 days per IRC § 6325(a). On an Installment Agreement of $25,000 or less, lien withdrawal under Form 12277 can be requested to clear title with the Erie County Recorder of Deeds.
Sample tax-resolution outcomes
Anonymized client matters drawn from our $100M+ aggregate tax-relief record across 2,000+ resolved cases.
| Year | Tax debt | Resolution | Final outcome |
|---|---|---|---|
| 2024 | $152,296 | IRC § 6159 Installment Agreement | Accepted at $25/month, partial-pay |
| 2024 | $138,296 | Streamlined Installment Agreement | Accepted at $25/month |
| 2023 | $130,555 | Partial-Pay Installment Agreement | Accepted at $50/month |
| 2023 | $128,206 | IRC § 6159 Installment Agreement | Accepted at $25/month |
| 2022 | $116,451 | Partial-Pay Installment Agreement | Accepted at $50/month |
Past results do not guarantee future outcomes. Each tax case is unique. Results depend on the specific facts of the matter, including the taxpayer's financial condition, compliance history, and the discretion of the Internal Revenue Service and the Pennsylvania Department of Revenue.
Why Victory Tax Lawyers for an Erie federal-tax case
Victory Tax Lawyers is California-Bar-admitted, not Pennsylvania-Bar-admitted. That distinction matters — and it does not block our work. The U.S. Tax Court is a federal court with nationwide jurisdiction; an attorney admitted to that court may petition and try cases at any of its trial locations, including Pittsburgh (the primary trial city for Erie petitioners) and Buffalo, New York (the alternate). IRS administrative practice runs on Form 2848 Power of Attorney, accepted from any attorney in good standing with any state bar plus an active Centralized Authorization File number. Most of our Erie clients never need a separately admitted Pennsylvania attorney because the case is, at its core, federal.
For administrative work before the Pennsylvania Department of Revenue — protests, audit responses, Compromise petitions under 72 Pa.C.S. § 9707, and Deferred Payment Plan requests — we file PA Form REV-677 Power of Attorney and handle the matter remotely. When a case must move to the Pennsylvania Board of Finance and Revenue (the state administrative tribunal at 1101 South Front Street, Suite 400, Harrisburg) or appeal further to the Pennsylvania Commonwealth Court (the intermediate appellate court that hears tax appeals from the Board of Finance and Revenue, sitting at 601 Commonwealth Avenue, Suite 2100, Harrisburg) or the Pennsylvania Supreme Court, we coordinate with locally admitted Pennsylvania counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the bigger exposure given Wabtec Lawrence Park RSU vests, Erie Insurance Group equity-comp, UPMC Hamot and Saint Vincent 1099 physician income, and Port of Erie FBAR and customs work, stays with us.
What distinguishes our firm: a California-Bar-admitted managing attorney with active U.S. Tax Court admission, an Enrolled Agent on staff for IRS administrative work, a 5.0 / 72-review Google rating, and $100M+ in cumulative tax relief secured across 2,000+ resolved matters. No marketing claim of being a Pennsylvania-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Erie taxpayer, at the same standard we apply to a Los Angeles client. Our 100% remote workflow runs through a secure document portal — you never have to travel to Robertson Boulevard.
Our seven-step process for Erie clients
Free consultation
A 30-minute call with a tax attorney to scope your matter, identify deadlines, and decide whether engagement is the right move.
Engagement letter
A written scope, fee structure, and conflict check. Flat fees for administrative resolution; hourly or hybrid for litigation.
Form 2848 and CAF
We file the federal Power of Attorney with the IRS and PA Form REV-677 with the Pennsylvania DOR, register on the CAF system, and step in as the contact of record.
Transcript and CSED analysis
We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, and identify tolling events.
Strategy memo
A written summary: the resolution path (OIC, IA, CNC, audit response, CDP, Tax Court), the timeline, and the realistic outcome range.
Filing and negotiation
We file the operative document — Form 656, Form 433-A(OIC), Form 9423, Form 12153, or a PA Board of Finance and Revenue petition through local counsel — and handle every IRS and DOR contact.
Compliance monitoring
After resolution we monitor compliance through the OIC five-year terms or the IA term, file future returns, and prevent default.
Two collection clocks: federal CSED and Pennsylvania's statute
The IRS has ten years from the date of assessment to collect a federal tax under IRC § 6502. After the Collection Statute Expiration Date, the debt is extinguished by operation of law. The clock pauses (“tolls”) when an Offer in Compromise is pending, when a Collection Due Process petition is filed, during bankruptcy, when an installment agreement is requested, and when the taxpayer is outside the United States for six months or more.
Pennsylvania runs a parallel state collection rule under 72 Pa.C.S. § 7805. The PA DOR generally must assess Pennsylvania personal income tax within three years of the return due date (extended for substantial omissions, with no statute on collection in cases of fraud or non-filing). Once a state tax lien is recorded in the Erie County Prothonotary's office, it remains effective until satisfied and is renewable under PA law. Many Erie taxpayers carry a federal CSED that will run out before the Pennsylvania state-lien clock — or vice versa. Pull both records and know both dates before agreeing to any payment plan or amended return that could restart a clock.
Erie tax authorities and venues
A working knowledge of the tribunals, agencies, and field offices serving Erie is what separates an answered Notice from a wage levy. Below is the working list our firm uses on every Erie matter.
Internal Revenue Service — Erie TAC
The federal tax authority, at irs.gov. The Erie Taxpayer Assistance Center operates at 130 West 9th Street, Erie PA 16501. Appointments required.
U.S. Tax Court — Pittsburgh and Buffalo trial sessions
The U.S. Tax Court holds regular trial sessions in Pittsburgh at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street, Pittsburgh PA 15219 (the primary trial city for Erie County petitioners, roughly 130 miles south). Buffalo, New York at the Robert H. Jackson United States Courthouse, 2 Niagara Square, Buffalo NY 14202, is the alternate roughly 130 miles east. Petitions are filed at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).
Pennsylvania Department of Revenue — Erie District Office
The state tax authority, at revenue.pa.gov. Headquartered at Strawberry Square, 4th & Walnut Streets, Harrisburg PA 17128, with an Erie district office at 448 West 11th Street, Erie PA 16501. Administers the flat 3.07% personal income tax under 72 Pa.C.S. § 304, the 8.99% corporate net income tax (phasing down) under 72 Pa.C.S. § 7401, the 6% state sales-and-use tax under 72 Pa.C.S. § 7202 (no Erie County add-on), withholding tax, and the Pennsylvania Inheritance Tax under 72 Pa.C.S. § 9116.
Pennsylvania Board of Finance and Revenue
The state administrative tax appeals tribunal. Seated at 1101 South Front Street, Suite 400, Harrisburg PA 17104. Hears second-level appeals from final decisions of the PA DOR Board of Appeals on personal income tax, corporate net income tax, sales and use tax, employer withholding, and inheritance tax. 60-day petition deadline under 72 Pa.C.S. § 9702 from the Board of Appeals decision. Further appeal lies to the Pennsylvania Commonwealth Court.
Pennsylvania Commonwealth Court
The Commonwealth's intermediate appellate court with original and appellate jurisdiction over Pennsylvania tax appeals. Seated at 601 Commonwealth Avenue, Suite 2100, Harrisburg PA 17120, with hearings also held in Pittsburgh and Philadelphia. Appeals from the Board of Finance and Revenue are filed here under 42 Pa.C.S. § 763. Further appeal lies to the Pennsylvania Supreme Court. Victory Tax Lawyers refers Commonwealth Court litigation to locally admitted Pennsylvania counsel; we handle the federal portion and the PA DOR administrative work directly.
City of Erie Treasurer
The municipal finance authority for the City of Erie. Office at the Erie Municipal Building, 626 State Street, Erie PA 16501. Page: erie.pa.us. Administers City of Erie real-estate tax billing and collection, business taxes, and municipal-services receipts. The Erie Local Earned Income Tax under Pennsylvania Act 32 is administered through the Erie County Tax Collection Committee and its designated collector for Erie residents and non-resident workers.
Erie County Treasurer
The county tax-collection authority. Office at the Erie County Courthouse, 140 West 6th Street, Room 110, Erie PA 16501. Administers Erie County real-estate tax collection, the Erie County Hotel Room Excise Tax, and other county fees. Page: eriecountypa.gov.
Erie County Assessor
The county assessment authority. Office at the Erie County Courthouse, 140 West 6th Street, Room 110, Erie PA 16501. Administers real-property assessments across Erie County, the Homestead and Farmstead Exclusion, and the Senior Citizen Tax/Rent Rebate program coordinated with the PA DOR. Property-tax assessment appeals run to the Erie County Board of Assessment Appeals, then to the Erie County Court of Common Pleas Civil Division.
U.S. District Court — Western District of Pennsylvania, Erie Division
Refund suits filed after payment of tax and exhaustion of administrative remedies under IRC § 7422 may be brought in the U.S. District Court (W.D. Pa., Erie Division), located at the Federal Building, 17 South Park Row, Erie PA 16501, or the U.S. Court of Federal Claims in Washington, D.C. Petitioners may also pursue the action in the Pittsburgh Division at 700 Grant Street.
IRS Independent Office of Appeals
The administrative-appeals body within the IRS that resolves cases without litigation. Erie cases run through the Appeals offices serving the mid-Atlantic and Great Lakes regions. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.
Taxpayer Advocate Service — Pittsburgh
An independent organization within the IRS that helps when normal channels stall. The Pittsburgh Local Taxpayer Advocate office at 1000 Liberty Avenue, Room 1525, Pittsburgh PA 15222, serves Erie County and Northwestern Pennsylvania. Page: taxpayeradvocate.irs.gov.
Erie County Recorder of Deeds
The recording office for Notices of Federal Tax Lien and Pennsylvania state tax liens affecting real property in Erie, Millcreek Township, Harborcreek, Lawrence Park, Fairview, North East, Corry, and the rest of Erie County. Office at the Erie County Courthouse, 140 West 6th Street, Erie PA 16501. NFTL recording on the wrong county's records fails to attach to title — a procedural defect that can be the basis of a lien-withdrawal request under Form 12277.
Speak with a tax attorney about your Erie matter
Free consultation, attorney-client privileged, no obligation. If a Notice of Deficiency, a Final Notice of Intent to Levy, or a Pennsylvania DOR Notice of Assessment is in front of you, the deadline to respond is real and short — call today.
Frequently asked questions — Erie tax
What is the Erie Local Earned Income Tax and how is it different from PA state tax?
The Erie Local Earned Income Tax is a 1.65% wage tax on residents of the City of Erie under Pennsylvania Act 32, administered through the Erie County Tax Collection Committee and its designated tax officer. Non-residents who work in Erie also pay a portion of the LEIT through their employer's withholding. This tax sits on top of, not in place of, the Pennsylvania state personal income tax of 3.07% under 72 Pa.C.S. § 304. An Erie resident pays roughly 4.72% combined on every wage dollar before federal tax. The local rate is lower than the Pittsburgh 3% resident LEIT and the Philadelphia roughly 3.75% Wage Tax, but the layering is the same. Pennsylvania also collects a $52 annual Local Services Tax in many municipalities; the City of Erie's LST applies to anyone who works in the City regardless of residency.
How does Pennsylvania Inheritance Tax work and who pays it?
The Pennsylvania Inheritance Tax under 72 Pa.C.S. § 9116 is paid on transfers at death from a Pennsylvania resident, or on Pennsylvania-situs real property and tangible personal property from a non-resident. Rates: 0% to a surviving spouse or a parent inheriting from a child under 21; 4.5% to lineal descendants and lineal ancestors (children, grandchildren, parents, grandparents); 12% to siblings; 15% to nieces, nephews, friends, and any other non-relative. Pennsylvania is one of only six states still imposing a separate inheritance tax. Form REV-1500 is filed with the Erie County Register of Wills at the Erie County Courthouse, 140 West 6th Street, within nine months of death. A 5% discount applies to tax paid within three months. Coordination with the federal estate-tax return on Form 706 is its own engagement layer when the gross estate is large enough to trigger federal filing.
Where is the closest U.S. Tax Court trial location to Erie?
The U.S. Tax Court holds regular trial sessions in Pittsburgh at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street, roughly 130 miles south of Erie — the primary trial city for Erie County petitioners. Buffalo, New York at the Robert H. Jackson United States Courthouse, 2 Niagara Square, is the alternate roughly 130 miles east, often more convenient for petitioners in the eastern part of Erie County and the New York border townships. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline from the IRS Statutory Notice of Deficiency under IRC § 6213(a) is jurisdictional — a single day late and the federal assessment becomes final.
What is the Pennsylvania Board of Finance and Revenue and what is its deadline?
The Pennsylvania Board of Finance and Revenue is the state's administrative tax-appeals tribunal, seated at 1101 South Front Street, Suite 400, Harrisburg. It hears second-level appeals from final decisions of the PA Department of Revenue Board of Appeals on personal income tax, corporate net income tax, sales and use tax, employer withholding, and inheritance tax. The petition deadline is 60 days from the Board of Appeals decision under 72 Pa.C.S. § 9702 — tighter than the federal 90-day Tax Court deadline. Decisions are appealable to the Pennsylvania Commonwealth Court within 30 days under 42 Pa.C.S. § 763. Victory Tax Lawyers handles the administrative track through the Board of Appeals and the Board of Finance and Revenue under PA Form REV-677; we refer Commonwealth Court litigation to locally admitted Pennsylvania counsel.
I work at Wabtec Lawrence Park (formerly GE Transportation) and have RSUs — why did I owe so much tax this year?
RSU vest events are taxed as W-2 ordinary income at the supplemental wage withholding rate, which is currently 22% federal on amounts up to $1 million per year (37% above). If your actual marginal federal rate is 32%, 35%, or 37%, you are underwithheld by 10 to 15 percentage points on every vest. Add 3.07% Pennsylvania plus the 1.65% Erie resident Local Earned Income Tax, and a single year of vesting can produce a $30,000 to $200,000+ balance due. The fix is W-4 adjustment plus quarterly Form 1040-ES under IRC § 6654 and Pennsylvania Form REV-414 estimates. Wabtec engineers, plant managers, and longtime GE Transportation legacy equity-holders see this pattern every vest cycle.
I am a UPMC Hamot or Saint Vincent physician with side 1099 income — what should I expect?
UPMC Hamot attending physicians, Saint Vincent Hospital and AHN Saint Vincent specialists, clinical-faculty members affiliated with Lake Erie College of Osteopathic Medicine (LECOM), and surgical specialists frequently carry side 1099 income from independent surgical centers, second-opinion telemedicine, pharmaceutical clinical-trial honoraria, expert-witness work, and royalty arrangements on medical devices or patents. The 1099 income is reported on Schedule C and subject to 15.3% SECA self-employment tax under IRC § 1401 in addition to ordinary income tax at the 32% to 37% federal marginal rate, plus 3.07% Pennsylvania and 1.65% Erie resident LEIT. Without quarterly Form 1040-ES payments under IRC § 6654 and PA Form REV-414 estimates, a strong 1099 year produces a five- or six-figure balance the following April. Resolution paths include partial-pay Installment Agreements, S-corporation restructuring to control SECA, and reasonable-compensation analysis if the 1099 work is run through an LLC or PC.
I work at Erie Insurance Group and have ISOs, RSUs, or a Schedule C agency — what do I need to watch?
Erie Insurance Exchange — the Fortune 500 carrier headquartered downtown at 100 Erie Insurance Place — pays a mix of W-2 base, RSU vesting in ERIE common stock, and in some cases ISO grants. The same 22% federal supplemental withholding shortfall applies to RSUs, and ISO disqualifying dispositions push ordinary-income inclusions plus potential AMT under IRC § 55. Erie Insurance independent agents who own their own agencies file Schedule C and face the IRC § 199A Qualified Business Income deduction phase-out for Specified Service Trades or Businesses — insurance agency and brokerage activities are SSTBs, and the deduction phases out above the inflation-indexed taxable-income threshold. Actuarial 1099 consultants in the Erie market face the same SSTB analysis. We model the SSTB phase-out, S-corporation election, and reasonable-compensation analysis together.
I work at the Port of Erie or in Great Lakes shipping — what are my FBAR obligations?
Any US person with a financial interest in or signature authority over a foreign financial account that exceeds $10,000 in aggregate at any point during the calendar year must file FinCEN Form 114 (FBAR) by April 15 (automatic extension to October 15). Dockworkers, ship captains, mates, and shipping-line officers who hold Canadian RBC, TD, BMO, or Scotiabank accounts — or who have signature authority on a Canadian shipping-company corporate account — trigger FBAR. Canadian RRSP and TFSA balances trigger Form 8938 FATCA reporting under IRC § 6038D above the higher per-taxpayer threshold (typically $50,000 single / $100,000 joint at year-end, with mid-year tests). Late or missed FBAR filings can be resolved through Streamlined Filing Compliance Procedures or Delinquent FBAR Submission, depending on the willfulness analysis.
I came to Erie as a refugee — do I need to report family accounts back home?
Yes, if you are a US citizen, lawful permanent resident, or otherwise a US person for tax purposes, and you have a financial interest in or signature authority over a foreign financial account exceeding $10,000 in aggregate at any point during the year, FinCEN Form 114 (FBAR) is required. This catches many Erie residents from the Bosnian, Iraqi, Burmese, Vietnamese, and other refugee-origin communities who maintain or signed onto family accounts at Raiffeisen, UniCredit, Sparkasse, or other overseas institutions. Form 8938 (FATCA) under IRC § 6038D adds a parallel reporting obligation at higher thresholds. The IRS Streamlined Filing Compliance Procedures (Domestic Offshore for US-resident filers; Foreign Offshore for filers who lived abroad) are designed for non-willful late filers and typically waive most of the harshest FBAR penalties.
I own a short-term rental near Presque Isle — what tax issues should I expect?
A Presque Isle State Park, bayfront, or Lake Erie peninsula short-term rental raises four federal tax issues: (1) IRC § 280A vacation-home rules limit deductions if personal use exceeds 14 days or 10% of rental days; (2) Schedule E versus Schedule C classification, with self-employment tax exposure under IRC § 1401 if hotel-like services are provided; (3) IRC § 469 passive-activity loss rules unless material participation is documented under Treasury Reg. § 1.469-5T; (4) cost segregation and bonus depreciation under IRC § 168(k) on the building, furnishings, and short-life land improvements. Pennsylvania adds its 6% Hotel Occupancy Tax under 72 Pa.C.S. § 7202 on rentals 30 days or less, plus a 2% Erie County Hotel Room Excise Tax. Many Erie STR owners are sitting on missed depreciation and Schedule E losses that a corrected return can recover within the three-year IRC § 6511 refund window.
What is Pennsylvania's collection statute of limitations?
72 Pa.C.S. § 346 gives the PA DOR three years from a return's due date to assess Pennsylvania personal income tax (extended for substantial omissions, with no limit for fraud or unfiled returns). Once an assessment is final, the DOR records a state tax lien under 72 Pa.C.S. § 7805 in the Prothonotary's office for the county where the taxpayer holds real property. The lien remains effective until satisfied and may be renewed by re-recording. The federal CSED under IRC § 6502 is a separate ten-year clock running from the federal assessment date. Coordinated case planning hinges on knowing both clocks before any action that could restart either one.
Can I be audited by both the IRS and the Pennsylvania DOR for the same year?
Yes. The IRS and the Pennsylvania Department of Revenue operate independently and share information through the IRS-state exchange program. A federal audit adjustment is routinely reported to Pennsylvania under the state's federal-change reporting rule (72 Pa.C.S. § 7330(b)), and vice versa. We coordinate the two audits to prevent inconsistent positions on the federal record from costing you on the Pennsylvania return — and on the Erie Local Earned Income Tax filing administered through the Erie County Tax Collection Committee.
Does Pennsylvania have an Offer in Compromise equivalent to the federal program?
Yes, but it is narrower than the federal program. The Pennsylvania Department of Revenue operates a Compromise program under 72 Pa.C.S. § 9707 for personal income tax, corporate net income tax, sales and use tax, and other Pennsylvania taxes. The DOR considers compromises based on doubt as to collectibility or doubt as to liability — the third federal ground, effective tax administration, has no Pennsylvania analog. The PA DOR also operates a Deferred Payment Plan program for taxpayers who cannot pay in full but can pay over time. All Pennsylvania returns must be filed before consideration, and current-year compliance is verified. We typically run a state Compromise in parallel with the federal Offer where both debts are real.
Can a California-Bar-admitted attorney represent me in Erie?
For federal IRS matters — yes. The IRS accepts Form 2848 Power of Attorney from any attorney in good standing with any state bar. The U.S. Tax Court is a single federal court with nationwide jurisdiction; an attorney admitted to that court may represent a taxpayer at any Tax Court trial location, including Pittsburgh (the primary trial city for Erie petitioners) and Buffalo, New York (the alternate). For Pennsylvania DOR administrative work, we file PA Form REV-677 Power of Attorney and handle the matter remotely through the Board of Appeals and the Board of Finance and Revenue. For formal litigation in the Pennsylvania Commonwealth Court or the Pennsylvania Supreme Court, we co-counsel with locally admitted Pennsylvania attorneys. Most engagements — audit defense, OIC, IA, levy release, Tax Court — are federal and stay entirely with our firm.
A lake-effect storm caused property damage and I missed the filing deadline — what can I do?
When a winter storm, blizzard, or other casualty is federally declared a disaster, the IRS routinely extends filing and payment deadlines for affected Erie County taxpayers and treats the event as reasonable cause for First-Time Abate is not available. Personal-use casualty losses are deductible under IRC § 165(h) only to the extent attributable to a federally declared disaster (Tax Cuts and Jobs Act narrowed the rule), and business and income-producing property losses remain deductible under IRC § 165(c). Documentation of the loss (photographs, contractor estimates, insurance correspondence) is the controlling evidence. Pennsylvania follows a parallel reasonable-cause analysis under 72 Pa.C.S. § 352 for late filings tied to declared disasters.
What if I have unfiled returns going back several years?
The IRS Voluntary Filing Compliance policy and IRM 5.1.11.6 generally require the last six years of returns to bring a taxpayer back into compliance. Filing prior-year returns is the first step before any OIC, IA, or CNC request — IRC § 7122(d) compliance is a prerequisite for a federal Offer. Refunds claimed on returns filed more than three years after the original due date are time-barred under IRC § 6511(b)(2). Pennsylvania follows a parallel filing-compliance posture; the DOR may assess based on federal-change reporting or estimate tax when a taxpayer fails to file. Erie Local Earned Income Tax compliance under Pennsylvania Act 32 through the Erie County Tax Collection Committee is a separate filing track for residents and non-resident workers.
About the author
This page was written and reviewed by Parham Khorsandi, Esq., Managing Attorney of Victory Tax Lawyers, LLP. Cal Bar #266658. Admitted to practice before the United States Tax Court. Mr. Khorsandi has resolved over 2,000 federal tax matters and secured more than $100 million in tax relief for clients across all 50 states.
Page last reviewed: . Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Pennsylvania statute citation references the Pennsylvania Consolidated Statutes Title 72. Every administrative authority links to its primary .gov source. Material changes to the law are reflected within 30 days of effective date.
Attorney Advertising. This page is provided by Victory Tax Lawyers, LLP for general informational purposes only. Nothing on this page constitutes legal advice, creates an attorney-client relationship, or substitutes for consultation with a licensed attorney about your specific tax matter. Prior results described or referenced do not guarantee a similar outcome. Each tax case turns on its individual facts, applicable law, and the discretion of the Internal Revenue Service, the Pennsylvania Department of Revenue, the U.S. Tax Court, the Pennsylvania Board of Finance and Revenue, the Pennsylvania Commonwealth Court, or other adjudicating body.
Victory Tax Lawyers, LLP is California-Bar-admitted with its principal office at 1100 S. Robertson Blvd., Los Angeles, CA 90035. The firm represents clients in federal tax matters nationwide via Form 2848 Power of Attorney and admission to the United States Tax Court. The firm is not admitted to practice in the courts of the Commonwealth of Pennsylvania; where a Pennsylvania state-court appearance or Pennsylvania Commonwealth Court tax litigation is required, the firm associates with locally admitted counsel.
IRS Circular 230 Disclosure: The discussion of U.S. federal tax issues on this page is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties imposed under the Internal Revenue Code or for promoting, marketing, or recommending to another party any tax-related matters addressed. For specific tax advice, consult independent tax counsel.
Related practice areas
Offer in Compromise
IRC § 7122 settlements
Installment Agreement
IRC § 6159 payment plans
Tax Lien Help
NFTL release and discharge
Tax Levy Defense
IRC § 6343 release
Audit Representation
IRS examinations
Penalty Abatement
IRC § 6651 relief
Back Taxes
Unfiled-return resolution
Pennsylvania state hub
Statewide PA practice
See other areas
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Authorities cited on this page
- 26 U.S.C. § 7122 — Federal Offer in Compromise
- 26 U.S.C. § 6159 — Installment Agreements
- 26 U.S.C. § 6321 — Federal Tax Lien
- 26 U.S.C. § 6325 — Lien Release and Discharge
- 26 U.S.C. § 6331 — Levy and Distraint
- 26 U.S.C. § 6343 — Release of Levy
- 26 U.S.C. § 6502 — Collection Statute Expiration
- 26 U.S.C. § 6213 — Tax Court Petition Window
- 26 U.S.C. § 6320 — CDP for Liens
- 26 U.S.C. § 6330 — CDP for Levies
- 26 U.S.C. § 6651 — Failure-to-File and Failure-to-Pay
- 26 U.S.C. § 6672 — Trust Fund Recovery Penalty
- 26 U.S.C. § 6015 — Innocent Spouse Relief
- 26 U.S.C. § 7202 — Willful Failure to Collect or Pay Over Tax
- 26 U.S.C. § 199A — Qualified Business Income / SSTB
- 26 U.S.C. § 174 — R&D Capitalization
- 26 U.S.C. § 280A — Dwelling Unit Used as Residence
- 26 U.S.C. § 165 — Losses (Casualty / Disaster)
- 26 U.S.C. § 217 — Moving Expenses
- 26 U.S.C. § 107 — Clergy Housing Allowance
- 26 U.S.C. § 117 — Scholarships and Fellowships
- 26 U.S.C. § 6038D — FATCA / Form 8938
- 26 U.S.C. § 1401 — Self-Employment Tax
- 72 Pa.C.S. § 304 — Pennsylvania 3.07% personal income tax
- 72 Pa.C.S. § 346 — Pennsylvania assessment statute of limitations
- 72 Pa.C.S. § 352 — Pennsylvania failure-to-file penalty
- 72 Pa.C.S. § 353 — Pennsylvania underpayment penalty
- 72 Pa.C.S. § 7202 — Pennsylvania sales and use tax
- 72 Pa.C.S. § 7240 — Pennsylvania responsible-person liability
- 72 Pa.C.S. § 7330 — Pennsylvania federal-change reporting
- 72 Pa.C.S. § 7401 — Pennsylvania corporate net income tax
- 72 Pa.C.S. § 7805 — Pennsylvania state tax lien
- 72 Pa.C.S. § 9116 — Pennsylvania Inheritance Tax
- 72 Pa.C.S. § 9702 — PA Board of Finance and Revenue petition deadline
- 72 Pa.C.S. § 9707 — Pennsylvania Compromise program
- 42 Pa.C.S. § 763 — Pennsylvania Commonwealth Court tax jurisdiction
- Pennsylvania Act 32 of 2008 — Local Earned Income Tax collection consolidation (Erie County Tax Collection Committee)